INTM215170 - Controlled Foreign Companies: before CTSA

Notice of direction: appeals - appeals from unconnected parties

The Board must give notices of the making of a direction to every company resident in the United Kingdom which has an interest in the controlled foreign company at any time during the accounting period. This means that appeals may be received from more than one company. This is not a problem if all the companies which appeal are members of the same group. The same goes for companies otherwise connected or associated with each other.

The Inspector may have a case where one or more of the appellants is unconnected with the others. The way the Inspector should deal with such an appeal may not be so easy. If an enquiry is received, it should be referred to CT & VAT, International CT.